2 other persistent courses of conduct and/or deriving substantial revenue from goods and services provided to individuals in this district. 6.
Venue is proper in this district pursuant to §§ 1391(b), (c) and 1400(b).
On April 29, 1997, United States Patent No. 5,625,776 (the "'776 patent"), entitled "Electronic Proposal Preparation System for Selling Computer Equipment and Copy Machines," was duly and lawfully issued by the U.S. Patent and Trademark Office ("USPTO"). A true and correct copy of the '776 patent is attached hereto as Exhibit A. 8.
On October 20, 2009, United States Patent No. 7,606,739 (the "'739 patent"), entitled "Electronic Proposal Preparation System," was duly and lawfully issued by the USPTO. A true and correct copy of the '739 patent is attached hereto as Exhibit B. 9.
CWC is the assignee and owner of the right, title and interest in and to the '776 and '739 patents, including the right to assert all causes of action arising under said patents and the right to any remedies for infringement of them.
INFRINGEMENT OF U.S. PATENT NO. 5,625,776
CWC repeats and realleges the allegations of paragraphs 1 through 9 as if fully set forth herein. 11.
Without license or authorization and in violation of 35 U.S.C. § 271(a), Defendant has infringed and continues to infringe at least claim 61 of the '776 patent by making, using, owning, operating, and/or maintaining one or more sales methods, sales systems, marketing methods and/or marketing systems, including, but not limited to www.teslamotors.com and all related instrumentalities used to deliver web pages from that domain, including related web servers and database servers and their associated software, e.g., to receive information identifying a customer's desired equipment features